MILARA MINUTES
MHHA OFFICE
October 16th, 2015
Start Time: / 1000-1130Committee Attendees: / Amy Parkinson, Rick Brummette, Bary Cargill, Kim Costello,Stacey Knierim-Clark, Joan
Support Staff:
Guest
/Crystal Foster from MILARA
Absent:
Topic / Discussion/Recommendations / Actions/Follow Up / Responsible Person / Target Completion Date
- Clarify Objectives
- Review Roles
Co-Chair: Kim Costello
Recorder: Amy Parkinson
Facilitator: Barry Cargill
- Review Agenda
- Work Through Agenda Items
A. Review/ approve minutes from last meeting. / June minutes discussed. Barry reminded that we wanted to review data. / Minutes approved. / Members
B. Review State Survey activities: Complaints, CASPER results, Deemed Status update. / Rick explained that the Regional Office was asked for clarification and Crystal explained that we were asking about where the date range was from. Chicago did not know the date range and the central office also could not give the objective data as well. Rick asked how the OIG would get the data? Crystal stated that they get the Keys and Casper Reports that have their own programming staff and CMS just asks for the data and doesn’t really know the parameters of the data. Larry Norvath was also asked by Rick and Crystal and Larry recommended that we as a stakeholder need to send a formal letter requesting the data parameters.
More agencies are not accredited any more and more will be reviewed via the CASPER data. This state group would like to see if there are decreases seen in outcomes over the past years vs improvements and wonder how we can determine that when the data is not clear. Also discussed the issue that perhaps the evaluations being done in MI are more stringent than the other state’s evaluations. Crystal explained that they only have one forum with other states where they have dialog, but the agenda is not usually around consistency in data collection, it is set by CMS. This state has requested this on the agenda, but currently has not been done. Barry shared that Missouri also has this issue.
Looking at the actual report, Amy asked if a date range is put in to actually run the report and Crystal said “no”, but she can put in up to at least 20 review items or even more if we would like. We all felt that we would like to see as many as possible at the next report. No other variables are possible.
Barry will also look to ask the accrediting bodies to see if they can run the same report to compare outcomes.
Rick is asking his department for list of agencies who have dropped their accreditation status. Crystal has 633 Home Health, 533 are deemed and 95 are not. 45 agencies dropped this last fiscal year. This number could be low for non-deemed as this data takes a while to reflect. The state does not have to resurvey for 3 years after their last survey. The agencies pay yearly for their accreditation status, but only get reviewed every 3 years. CMS is who notifies the state of the need for survey. The CMS connection was asked if this list “1666” data can be shared with our state organization. He just asked the question today. If the organization changes their accreditation then CMS may retract the 1666. CHAP and ACHC are usually notifying the state, but the Joint Commission may not be as forthcoming. Barry explained that many switch from Joint Commission to go to one of the other two as they are less expensive. Crystal looks at all of these and reviews to see if they have changed or actually dropped their certification. Barry also explained how the private duty agencies are not required to be accredited or state licensed. We are recommending accreditation as the minimum standard for “best practice”.
Rick responded that there is a lot for the state to keep track of and that is why they have the analyst. Hospitals have much less variability.
Crystal 115 certified Hospices, 80 are deemed and 35 are not. 2 or 3 are non-licensed hospices, 18 hospice residences are a subset of the 115. Most of these are accredited. Maybe 3 are not accredited. Barry stated his surprised that the home health is dropping their accreditation more so than the hospices. 15 or 20 are pending licensing. 5 – 10 are waiting CMS to approve. They must be licensed first, cannot see any patients until CMS allows them to see (they get a 6 month license). State surveys after that to assure they are ready for licensure.
Barry expressed concern that there are some hospices stating that the state surveyors are trying to influence the hospice to “not get accredited” and may ask about whether this is required. Crystal lets them know they need this initially, but lets them know it is not required after approval by the state. The state reviewers do not have any opinion regarding accreditation status in Crystal’s point of view. She felt they were naïve about this. Barry explained that it wasn’t in response to the agency question, but was offered up as a suggestion to the agency. Rick stated that he felt the communication would have only been factual. The surveyors should not state anything pro or con for accreditation. Barry stated that there are obvious movements away from accreditation and would like to see this trend reverse as it is felt to be “best practice”. The state cannot afford to do more surveys (per Crystal), but understands the issue and will share with the surveyors to assure they are not pushing the idea to “not get accredited”. Crystal would like to have names of surveyors if possible.
Also explained that many certified agencies
Joan asked if there was an HER that does a really good job with individualizing a care plan? Rick did not know the differences, but wanted to ask his field staff about this.
Went thru each deficiency for both home care and hospice to have Rick tell us what we are being most cited for in his review. We moved some detail regarding hospice regs to end of meeting as Rick would like to look some of the tags up to be sure he is clear.
Barry would like to know if there might be an option for an education program to help improve the outcomes of the state reviews. This would be preferred to be in addition to the state conference where Larry will be present. It would be helpful to at least review the top 10 common deficiencies and what was being looked for and how it could be improved upon with examples. / This group to develop a letter to request how the reports are prepared and where the data comes from so that we can plan an action to improve correctly.
Crystal is to run a report including all data items and bring to next meeting.
Also to bring a list of agencies (both home care and hospice) that have dropped their accreditation status over the past year.
Rick and Crystal to discuss with their state surveyors the importance of supporting accreditation by home health and hospice agencies as it is considered “best practice” and allows for a very thorough audit of each type of agency. It does not necessarily replace the state, but helps them assure quality remains in the state.
Plan to discuss how to implement education program next meeting. / Members
Crystal or Rick
Crystal or Rick
Crystal and Rick to report on their conversations with their team members.
All members / January 2016 mtg
Jan 2016 mtg
Jan 2016 mtg
Jan 2016 mtg
Jan 2016 mtg
C. Questions and Answers for MDLARA representative. / Amy asked if the agency that was mentioned at the last meeting as potentially receiving monetary penalities, if they did get the penalty? Crystal answered yes. The agency did have penalties imposed and they paid and are still in business. CMS has a grid that they follow after the second visit and the penalty is based per day starting with that second visit. The state has to verify that they have complied. They had about 20 days to become compliant and the state took 3 days to verify (included in the 20). They paid $5000 per day for this penalty. The agency should know what is being reviewed as they would have gotten this information at their first visit. The second visit may be clean and validate that the issue is fixed. If not, then you begin the penalty. This can go for up to 6 months until it is fixed. The state will return as often as necessary. If the state recommends termination, they have to have good reason. Only two have been recommended as of this date. The first one the timing of compliance was not appropriate, but CMS allowed it to be non-penalized . If you waive your appeal rights, there is a 35% discount on the penalty. That agency did get the 35% discount. The other issue is that it is not just the state of MI and other states are also required. Terminations that are being appealed go to the ALJ. If they win or lose the appeal, the state is not always clear on the outcome. Crystal stated that in the past 5 years, maybe 4 home care and 1 hospice loss of certification has occurred. Agencies must be actively treating patients. They cannot hold certification without seeing patients. What criteria sets a revalidation survey? CMS sets a number at random each year. Last year there were 6-7 and 2-3 Hospices done.
State Auditor General has audited 11 of our agencies. This state agency is not working with Milara dept on this. Amy described the audit as her agency participated. Rick had been asked by that department to share numbers of certified agencies and names.
Barry asked if a legislator and Judge are not clear on whether a HHA needs to be background checked, who deals with that? This bureau is requiring only those agency home health aides that are employed by Medicare certified agencies to be required to have the background checks. The aid in questions was employed by a certified agency. It is not clear in the state statute on background checking of WHO and WHEN the check is to be done. / Rick to help clarify any problems seen with agencies not understanding the appeal process.
Also to clarify when background checks are required for agency workers that go into patient’s homes to provide care – certified as well as private duty for non-certified agencies? / Rick / Jan 2016 mtg
- Review Meeting Record and Assignments
January 5th 2016 at 10:00am
April 5th 2016
June 28th 2016
October 4th 2016 / Amy to send handouts and minutes/ agenda to Mary P to send out to all attendees for the next meeting. / Amy / Prior to next meeting
Amy M. Parkinson11 - 20- 2015
______
, ChairpersonDate
This is a confidential professional/peer review and quality assurance document of the Hospital. It is protected from disclosure pursuant to the provisions of MCL333. 20175, MCL333.21513, MCL333.21515, MCL331.531, MCL331.532, MCL331.533, MCL330.1143a and other state and federal laws. Unauthorized disclosure or duplication is absolutely prohibited.
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